1. About us
ETC Management Limited (company no. 12165332) is the data controller of the personal information we hold about you.
We are registered as a data controller with the Information Commissioner's Office under data protection registration number ZA820221.
2. Contact us
By email: firstname.lastname@example.org
ETC Management Ltd
Gridiron, One Pancras Square
London, N1C 4AG
If you are located in the European Union, you can also contact our EU representative as follows:
ETC Issuance GmbH
Thum-Und Taxis-Platz 6
Frankfurt Am Main 60313
3. Personal information we collect
We collect personal information about you from the different sources listed below.
You may provide us with personal information directly, including when you:
The categories of personal information you provide may include:
We will indicate to you where the provision of certain personal information is required in order for us to provide you certain services. If you choose not to provide such personal information, we may not be able to provide the services you have requested.
We also collect, store and use information about your use of the Site, and about your computer, tablet, mobile or other device through which you access the Site. This includes the following information:
We will mostly collect the categories of personal data referred to above from you directly. However, we may also obtain personal information about you from the following third parties:
We may anonymise and aggregate any of the personal information we collect about you (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Site and our services and developing new products and features. We may also share such anonymised information with others.
The Site is not intended for or directed at children under the age of 18 and we do not knowingly collect personal information relating to anyone under this age.
4. How we use personal information
As a data controller, we will only use your personal information if we have a legal basis for doing so. The table below sets out the purposes for which we use your personal information as well as the legal bases which we rely on to process your personal information.
|Categories of personal data||Purposes of processing||Lawful basis for processing|
|Contact details; KYC information||To carry out KYC where you or the organisation you work for are seeking to establish or maintain a supplier or counterparty relationship with us.
To verify your identity when you submit a redemption request in respect of securities you hold which have been issued by ETC Issuance GmbH.
|Compliance with legal obligation (namely, relating to our AML obligations).
Compliance with legal obligation (namely, relating to our AML obligations).
|Contact details; marketing data||Marketing and advertising (including sending you newsletters, inviting you to events which we believe may be of interest to you and measuring the effectiveness of our marketing).||Consent (if required under applicable law).
Where consent is not required under applicable law (for example, where we are marketing to corporate email addresses), such processing is necessary in our legitimate interests, namely to develop and grow our business.
|Contact details; employment details||To process your request for investor information relating to the ETC Group, including contacting you to confirm whether your request is legitimate.||It is in our legitimate interests to ensure that we do not give out sensitive corporate information to individuals who have no intention in investing in the ETC Group or otherwise have no right to access such information.|
|Correspondence and communications data; contact details||To respond to queries and complaints and provide you with information and materials that you request from us.
To communicate with you as necessary to provide you with our services.
|It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to maintain good customer relations.
It is in our legitimate interests to communicate with you in respect of the provision of our services in order that we can properly carry out our services.
|Technical Data; Usage Data||To analyse your usage of the Site for the purpose of improving the Site and to ensure that content is presented in the most effective manner for you.||Consent.|
5. Who we share your personal information with
We disclose personal information with the following recipients to achieve the purposes set out above or as otherwise described below:
In addition, we may share your personal information with other third parties if you have provided your consent for us to do so.
6. International data transfers
We may need to transfer your personal data to third party service providers which are located outside the UK and European Economic Area (“ EEA ”).
In the event we need to transfer your personal data to a country which is not recognised by the UK government or EEA Commission (as applicable) as ensuring an adequate level of protection for personal data, we shall ensure that appropriate safeguards are in place to ensure adequate protection for your personal data (for example, by entering into standard contractual clauses with the recipients of your personal information).
Further details regarding the relevant safeguards we implement can be obtained from us on request using the contact details set out above.
7. Your rights and choices
You have the following rights in respect of the personal information we hold about you under applicable data protection law:
Please note that not all of the above rights are absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.
If you wish to exercise one of these rights, please contact us using the contact details set out above.
8. Data retention
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.
9. Data security
We use appropriate technical and organisational security measures (including encryption) to protect personal information both online and offline from unauthorised use, loss, alteration or destruction. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.
Despite these precautions, however, we cannot guarantee the security of information transmitted over the internet or that unauthorised persons will not obtain access to personal information.
10. Cookies and similar technologies
The Site may, from time to time, contain links to and from the websites of our business partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
If you have any queries or complaints about how we process your personal information, please contact us using the details set out above.
You also have the right to lodge a complaint to your national data protection authority. The relevant data protection authority in the UK is the Information Commissioner's Office ( www.ico.org.uk ). If you are resident in the EEA, you can find details regarding your local data protection regulator here .
13.Changes to this policy
Last updated: 20 th May 2022